One of the failings of the SNRAMP is that it blocks recreational access to the Natural Areas.

Visitors are required to stay on the trails, and just about the only thing you can do is walk along the prescribed trails. No wandering off to look at a flower or bird or butterfly or to perch on a rock in the sun. In some cases, actual fences are being installed to keep people on the trail. Many miles of “social trails” – the trails that exist only because people use them – are being closed or “relocated.” This increases potential conflict among park users; kids, joggers, walkers, naturalists, dogs, are all squished into the same 5-15 foot path while the acres of “Natural Area” remain unusable.

At the same time, they’re closing off-leash dog-play areas, denying access to popular park features like climbing rocks, and removing benches because people actually sit on them. The bench beside the Murdered Tree on Mt Davidson was removed because it was “an attractive nuisance” – it had a great view so people liked to go there.

Read on for more details.

The Significant Natural Resource Areas Management Plan (SNRAMP), which is evaluated by the Draft Environmental Impact Report (DEIR), announces these restrictions on recreational access in the natural areas:

SNRAMP “…calls for closing 54,411 feet (10.31 miles) of social trails and creating 5,897 feet (1.1 miles) of new trails, resulting in a new decrease of 48,514 feet (9.2 miles) or 23% of trails in natural areas.” (DEIR, page 256)

SNRAMP restricts all public use in the natural areas to the trails that will remain: “Public use in all Natural Areas, unless otherwise specified should encourage on-trail use…interpretative and park signs should be installed …to ‘Please Stay on the Trail.’ If off-trail use continues…permanent fencing shall be considered…” (SNRAMP, page 5-14). This policy is not mentioned in the DEIR.

The DEIR also announces plans to close 19.3 acres (20.3%) of the legal off-leash space in the natural areas, i.e. 16.4% of all legal off-leash space available in all city parkland. (DEIR, page 257)

Despite these plans to severely restrict all forms of recreation in the natural areas, which are 25% of all city managed parkland in San Francisco, the DEIR concludes that the impact on recreation will be “less than significant.” The DEIR’s analysis of impacts on recreation was inadequate for the following reasons:

The DEIR did not adequately consider the impacts on recreation and visitor experience caused by the closure of 10.31 miles of trails, including many social trails.

The DEIR did not consider negative impacts on recreation and visitor experience from the Natural Areas Program’s extensive use of fences to force people to stay on trails, nor did it consider impacts from the removal of benches in natural areas.

The DEIR did not consider the negative impact on recreation for park neighbors and users because NAP controls over 50% of the park in 27 out of 31 parks with natural areas (only four parks with natural areas have less than 50% of their total area controlled by NAP).

The DEIR did not adequately consider the negative impact on recreation from the intentional planting of threatened or endangered plant species and reintroduction of legally protected animal species in natural areas where they do not currently exist.

The DEIR did not adequately address the impact on recreation of the closure of off-leash Dog Play Areas, especially the potential closures of up to 80% of all legal off-leash areas on city parkland which the DEIR informs us could be the result of “monitoring” of the remaining off-leash areas.

The DEIR did not adequately address the impact on recreation, aesthetics, and visitor experience of poor maintenance in natural areas.

1. TRAIL CLOSURES

As acknowledged in the DEIR, a 2004 Recreation Assessment conducted for the Recreation and Park Department reported that the number one recreational facility need was more trails. Of the residents surveyed, 67% reported participating in walking or running, the highest percentage for any of the 26 activities listed in the Assessment. People want more trails, not less.

According to RPD General Manager Phil Ginsburg, the majority of trails in San Francisco city parks are located in the natural areas controlled by NAP (private conversation, June 1, 2012; he said this when asked to explain why the “trail restoration” part of the 2008 Clean and Safe Neighborhood Parks Bond was restricted to trails in natural areas). Thus, the SNRAMP’s proposed closure of 23% of the total length of trails in natural areas marks a significant decrease in the length of trails available to the public systemwide, not just in the natural areas. There is simply not enough trail mileage in non-NAP parks to adequately replace the mileage lost in the natural areas. Thus the trail closures will have a more significant negative impact on the majority of San Franciscans who want more trails on which to walk or run. This aspect of the trail closures was not mentioned in the DEIR.

By closing off the areas currently accessed by the trails that will be closed, the SNRAMP will reduce the variety of experiences park users can have (fewer different areas to see). With less mileage available to walk, the closures will also discourage people from taking longer walks. Neither of these impacts was considered in the DEIR.

Many, if not most, of the trails scheduled for closure are “social trails,” trails created by park users, not by park staff. There is usually a reason people create social trails; they prefer to take a more direct, faster, or more scenic path from Point A to Point B than the path RPD staff have told them they should take. Frequent visitors are the ones who create social trails by walking off an official trail time and time again. People new to a park will likely stay on official trails; they don’t know where else to go. The closure of social trails will therefore have a greater impact on people who walk frequently in the parks, degrading their experience of the park by forcing them to walk in places they clearly would rather not.

When the University of California at Santa Cruz opened in the 1960s, administrators paved few paths between the colleges. They chose to wait to see what paths the students “naturally” created on their own to get from one place to another, and then paved the social trails that resulted. The social trails became the official trails. NAP has taken the opposite approach, deciding where people will be allowed to walk with little, if any, public input. And when the public has expressed a desire for something different than what NAP wants (by voting with their feet and creating a social trail), the response is to destroy the social trail. NAP is working at cross-purposes to the majority of San Franciscans who want more trails, and who try to show NAP where they want those trails to be when they create social trails.

Social trails also spring up when people want to enter or leave a park at a location where there is no “official” trail that will allow them do so. For example, over the years, people created a social trail at the northwestern corner of Grandview Park. The only “official” park access comes from trails on the eastern and southern sides of the park. To get to the official trails, people living on the north and western sides of the park are forced to walk in the street that surrounds the park, an option they clearly didn’t like since they created a trail to the top of Grandview that began in the park’s northwest corner. The recent closure of the social trail at Grandview by NAP has made it harder for the people who live north and west of the park to access it. The DEIR did not address the loss of accessibility to parks by the closures of some social trails.

Erosion can be a problem with social trails, but the response should be to mitigate erosion where it occurs, not to close the trail. The DEIR did not consider mitigations to these erosion problems other than closure.

2. MORE FENCES AND FEWER BENCHES

“Stay on Designated Trail” Billy Goat Hill

The DEIR does not address the impacts on recreation and visitor experience of being restricted to the trails in the natural areas. Being restricted to trails prevents many different types of recreation. Visitors can’t spread a blanket on the ground and have a picnic or sunbathe while reading a book. Families can’t play ball or Frisbee, fly a kite or a model airplane on a trail. Being confined to a trail essentially prohibits many other forms of recreation. Signs have been erected in the natural areas to inform the public that they are confined to the trails. The DEIR makes no mention of this policy or the restrictions it imposes on the recreational preferences of park visitors.

Fences have been erected by NAP alongside trails to enforce this restriction. With fences in place on either side of a trail, a child is physically prevented from exploring plants and bugs on the ground just off of the trail, or following a butterfly or moving to see the bird she can hear calling. Fences, no matter how attractive they are, create a “look, Don’t Touch” museum-like feel to the park. That is not what most people want in their neighborhood parks.

Where trails have recently been “restored” in natural areas, NAP has erected fences on both sides of the trail, to force people to stay on the trails. These recently completed projects are a preview of the fences that the public can expect to be installed in all the natural areas as SNRAMP is implemented over its 20-year lifespan.

Grandview, May 2012

Corona Heights, May 2012

These are not temporary fences. They will remain in place to keep people from straying off the trail for years to come. Putting a fence on both sides of a trail creates a “cattle chute” feeling that many people find unappealing. Their park experience is seriously degraded by the presence of these fences. The DEIR does not address the issue of impacts of permanent or semi-permanent fences on recreation, nor does it address the impact on visitor experience of creating “cattle chute” trails in neighborhood parks.

When all recreational users are confirmed to a trail, it creates unnecessary conflicts between different user groups. When joggers, dogs being walked on 6’ leashes (as allowed by law), bicycles, birders seeking quiet, are all confirmed to the small space of a fenced trail, conflicts are inevitable. These conflicts are mitigated, if not avoided altogether, by giving people the option of stepping off the trail to accommodate other park visitors. Of all the negative impacts of the Natural Areas Program, perhaps the most devastating has been the increased conflicts it has caused in our parks. Park visitors who have co-existed in peace for generations are now pointing fingers at one another, blaming one another for the loss of their recreational liberty.

NAP has a history of removing benches from areas under its control. For example, a bench on an overlook at Mt. Davidson, one of only two benches in the park, was recently removed by NAP. There was nothing wrong with this bench. It was apparently removed because it was perceived by NAP staff to be detrimental to the native plants that grow in that area. There is now no place to sit (except on the ground) to either rest or reflect while looking at the view. This is a particular hardship for seniors and others with more limited mobility, who now have no place to sit after a strenuous uphill hike. Despite park neighbors’ and users’ pleas to replace the bench, NAP has so far refused to do so. The lack of benches or places for people to rest without having to sit on the ground impacts all recreational users of the parks, even those who only want to walk on trails.

The final EIR must acknowledge the SNRAMP policy to confine all recreational access in the natural areas to fenced trails. This restriction has a significant impact on recreation in the parks of San Francisco and it should be recognized as such by the final EIR.

3. NAP CONTROLS ENTIRE PARKS

In over half of the parks with natural areas (17 of 31 listed in Table 5 of the DEIR), NAP controls the entire park. Entire parks have become essentially single-use parks – natural areas only. In an additional 10 parks, NAP controls over 50% of the park. In only four parks does NAP control less than half of the park.

For those parks in which NAP controls the entire park, there are no recreational uses allowed in the entire park other than walking on a trail (Bernal Hill is the one exception, with off-leash dog walking allowed in the nearly half of the park that is designated as MA-3). Parents hoping to play catch with their child must find another park in which to do so. People wanting to sit on a blanket in the sun must go somewhere else. When you add in the parks with more than half of their land controlled by NAP, 87.5% of parks with natural areas in them will have significant restrictions on access and recreation. The final EIR must consider this impact on recreation and access.

Within all the natural areas, more than half of the land (57%) is designated as MA-1 or MA-2. These are the management zones with the most severe restrictions on recreation. In 7 parks, all of the land in the natural area is designated as MA-1 or MA-2. These parks will see even more significant impacts on access and recreation than parks with at least some of their land designated as MA-3. Recreation restrictions from different management zones, and how much of a park is made up of each zone, must be considered in the final EIR.

In some cases, the parks completely controlled by NAP do not have non-NAP parks close by. Thus people who want a non-NAP park experience (for example, to play catch with their children, friends or pets) will be forced to go to another park outside of their neighborhood. This will force many into their cars to drive to a non-NAP park. This increase in automobile usage and its attendant increases in pollution and global warming effects are not addressed in the DEIR.

4. PLANTING AND/OR REINTRODUCING THREATENED OR ENDANGERED SPECIES

In the SNRAMP, NAP expresses its intent to plant threatened or endangered species throughout the natural areas, including many places where they are not currently found. The mere presence of these species triggers a number of additional protections and access restrictions required by the federal Endangered Species Act and similar state and local laws The intentional planting of legally protected species where they are not currently found makes restrictions on recreational access (indeed all access) a fait accompli. Once the plant is in the ground or the animal is known to exist, it MUST be protected and recreational access MUST be restricted.

We have two specific examples of the consequences of reintroducing endangered species to our parks. In the case of Sharp Park, two endangered species of animal are known to exist. To our knowledge, these animals were not reintroduced by humans. The DEIR proposes to reconfigure the golf course to accommodate those legally protected species. The scale of that project is described in detail by the DEIR. We can’t imagine how much this project will cost to implement. However, despite the scale of this monumental effort, San Francisco is being sued by organizations which do not believe that the proposed accommodations are adequate and therefore violate the Endangered Species Act. These organizations demand that the golf course be closed entirely and that all recreational access be confined to “viewing zones” behind fences. Essentially, they want the entire 411 acre park turned over to the two endangered species.

The effort of the Natural Areas Program to reintroduce the endangered Mission Blue butterfly to Twin Peaks is a more clear-cut example of the potential for the implementation of SNRAMP to eliminate recreational use of San Francisco’s parks, because the butterfly did not exist there prior to the efforts of the Natural Areas Program to reintroduce it. In other words, the reintroduction was a discretionary act. The Natural Areas Program is willfully subjecting Twin Peaks to the potential to be closed to the public. The federal recovery plan for the Mission Blue previews these restrictions:

“Recreational impacts pose a substantial threat to mission blue butterfly habitat…One of the contributing factors to the apparent extirpation of this butterfly on Twin Peaks is heavy recreational use by off-trail hikers, and motor-bike activity all of which are prohibited.”

SNRAMP informs us that the Natural Areas Program intends to reintroduce the endangered Mission Blue butterfly in McLaren Park and Bayview Hill.It is, however, silent about what recreational access restrictions may be required to support the population of a legally protected species.

In its section on Recreation (p. 252), the DEIR says that the Notice of Preparation Scoping process identified several concerns about recreation, including: “Effects of the introduction of endangered/threatened species on recreational opportunities, public access, and the administration of local public lands.” Despite this acknowledgment, there is no discussion of impacts on recreation caused by intentional planting of sensitive species where they are not currently found.

The final EIR must acknowledge that the Natural Areas Program intends to reintroduce legally protected species of plants and animals to the Natural Areas. It must inform the public of what recreational access restrictions will be required to accommodate those species. When the loss of recreational access is anticipated, the final EIR must mitigate for those impacts by providing commensurate recreational opportunities in San Francisco.

5. DOG PLAY AREA (DPA) CLOSURES

The DEIR does not adequately consider impacts on off-leash recreation from the SNRAMP. The DEIR addresses only the impacts on remaining DPAs, and on recreation, of the immediate closure of 16.4% of the total legal off-leash space in city parks once the SNRAMP goes into effect. However, the DEIR concludes that impacts of these closures on remaining DPAs, recreation, people driving to other DPAs, etc., will be minimal.

The SNRAMP makes clear that NAP will monitor DPAs in four parks – McLaren, Buena Vista, Bernal Hill, and the Golden Gate Park Oak Woodlands – where DPAs are located either within or adjacent to natural areas. These DPAs, combined with the one scheduled for closure at Lake Merced, constitute roughly 80% of the legal off-leash space in all city parks. SNRAMP also makes clear that if NAP claims the monitoring shows impacts on theses natural areas from the dogs, the DPAs will be closed.

In other words, initial closures of dog play areas will be 16.4% of all dog play areas in San Francisco, but SNRAMP announces the potential for 80% of all dog play areas to be closed in the future. Since no evidence is provided by the DEIR that any damage has been done by dogs in the dog play areas that are being closed immediately, no evidence is likely to be provided to close most of the dog play area that would remain after the immediate closures.

In fact, in the one dog play area which will be closed entirely and immediately, both SNRAMP and the DEIR say that use of this area by visitors with dogs is minimal: “…the DPA at Lake Merced is not heavily used…” (DEIR, page 258) One wonders what the justification is for closing this DPA if it is not heavily used and no evidence is available that damage has been done by dogs.

The DEIR states that it cannot analyze the impacts of possible GGNRA closures because they have yet to be finalized. However, we know the amount of off-leash areas in the GGNRA proposed for closure in January 2011: 90% of existing off-leash space on GGNRA lands have been proposed for closure. The final EIR should analyze the cumulative impacts of the maximum amount of closure proposed by both SNRAMP and the GGNRA. We saw on “Tsunami Friday” what those impacts could be. The GGNRA closed both Fort Funston and Ocean Beach to all visitors on the morning of Friday, March 11, 2011 because of concerns that a tsunami triggered by a major earthquake in Japan would strike the coast. On Tsunami Friday, a Recreation and Park Department staff member counted over 200 dogs at once in the Pine Lake DPA at 10 am, ten times more dogs than on a normal weekday (usually about 20 dogs at any one time), and more than three times the maximum number of dogs normally seen on busy weekends (about 60 dogs). This example graphically illustrates the potential impact on remaining DPAs of significant closures of off-leash space. Forcing so many more dogs into remaining DPAs day after day will undoubtedly lead to serious degradation of those remaining DPAs thereby creating the conditions that would justify closure in the future.

Without providing any analysis, the DEIR concludes the cumulative impacts of closure of off-leash areas by the GGNRA and those proposed by SNRAMP are “significant and unavoidable.” So, in this rare instance in which the DEIR acknowledges significant impact on the environment and on recreational opportunities in San Francisco, it gives itself a free pass: “It’s unavoidable.” We beg to differ. The final EIR has options that must be considered. The obvious and responsible thing to do is to NOT close any dog play area if there is no evidence that dogs are harming those areas.

The DEIR repeatedly justifies the exclusion of off-leash recreation because it says dogs have a significant negative impact on plants and wildlife. Yet it offers no evidence to support the claims of impacts. The DEIR repeatedly says dogs MAY be impacting protected plant species or wildlife (ppgs, 298, 305, 306, 472, 502, 517), yet offers no evidence these impacts are actually occurring or ever have occurred. After each of these claims, the DEIR goes on to say: Dogs MAY continue to impact plants or wildlife. If there is no proof of an impact, then that impact cannot “continue.” EIRs must be based on observed, documented impacts, not speculation about things that “may” happen at some point in the future. The final EIR must alter its analysis to address this and base any restrictions on recreation involving dogs on actual observed impacts.

6. POOR MAINTENANCE

The 2012 work plans for the Natural Areas Program (see Attachment IV-A, obtained by public records request) help us to understand why the natural areas are such a mess. The work plans inform us that NAP and its volunteers and contractors plan to spend a total of 358.5 days taking care of 1,075 acres of natural areas in 2012. Each acre of natural area will therefore receive one-third of one day of maintenance for the entire year. Some natural areas have not been scheduled for any maintenance and several as few as one day for the entire year.

There are countless stories of volunteers who spent long hours planting in NAP areas, only to see absolutely no maintenance performed once the plants were in the ground. Not surprisingly, many of these plants die, creating unsightly vistas of dead or dying plants. People are much less likely to want to walk in natural areas that are poorly maintained, a negative impact on recreation that is not addressed in the DEIR.

Poor maintenance is important because NAP is exempt from the Maintenance Standards mandated by Proposition C passed by San Francisco voters in 2003. Prop C required the Recreation and Park Department, with help from the Controller’s Office, park advocates and the general public, to develop maintenance standards for parks. The standards define the desired conditions of park features such as lawns, trees, and trails, and are used to assess and evaluate conditions in San Francisco parks each year. In the San Francisco Park Maintenance Standards Manual (August 2006), there is a single maintenance standard for open space – cleanliness, defined as: “From a 10 feet distance (i.e., from the nearest path), open space is free of litter and debris.” The manual goes on to say that the standard is met if no more than 15 pieces of litter are visible in a 50’ by 50’ area or along a 200’ line, and that the standard is not met if needles, condoms, broken glass, and/or feces are present.

Certainly people in natural areas, including those walking on trails, have a right to expect the natural areas to meet such a simple cleanliness standard. However, the Manual goes on to say: “Open space-natural areas are not included in this standards manual, and therefore, are not inspected.” The DEIR should consider the impact on aesthetics and recreation of the woeful lack of maintenance in natural areas.

The final EIR should also consider the mitigation of scaling NAP back to a few areas that it can adequately maintain with its existing staff and budget, compared to the current plan to spread maintenance hours so thin because they are trying to cover too many natural areas. One of many reasons why the Natural Areas Program is controversial is that it is too big. It has claimed hundreds of acres in which there were no native plants whatsoever. It has bit off more than it can chew. Much of what is now on its plate should be taken back and returned to its “natural state,” i.e., without pesticides, without fences, without moonscapes created by eradicating existing vegetation.

Conclusion

The final Environmental Impact Report for the SNRAMP must:

Analyze the impacts on recreation of confining all recreation to trails, as well as the closure of trails in natural areas

Analyze the impact of restricting all recreational access to trails enforced by fences on recreation and aesthetics, especially erecting fences on both sides of trails, as well as impacts from the removal of benches in natural areas

Analyze impacts on recreation and access resulting from the designation of entire parks as natural areas with consequent impacts on recreation and aesthetics.

Analyze the impacts on recreation and access resulting from the intentional planting or reintroduction of legally protected species of plants and animals in natural areas where they do not currently exist

Analyze the maximum possible closures of all DPAs in natural areas (80%), not just the minimum possible (16.4%), and provide evidence of impacts claimed to be caused by dogs

Analyze impacts on aesthetics and recreation of poor maintenance of natural areas.

If this information is provided in the final Environmental Impact Report, it will undoubtedly conclude that the impact of SNRAMP on recreation is significant and requires mitigation. The obvious mitigation is to decrease the size of the natural areas to a size that can be maintained adequately and which does not restrict recreational opportunities.